Frequently Asked Questions: Trade Aggregation

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These Frequently Asked Questions are part of a series of frequently asked questions that address four primary areas of interest to investment advisers:      Compliance Program Components;      Daily Operations;      Client Protection; and      Registration … Continued

For 2 Advisers Cherry Picking Season is Over!

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In two separate administrative actions, the SEC barred two state-registered investment adviser for allocating trades in client accounts in a manner that disadvantaged their respective clients. The SEC also fined the heck out of them.

FBI Probes High Speed Trading

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The Federal Bureau of Investigation has launched a wide-ranging investigation into high-speed trading with an eye on whether some firms are acting on fast-moving market information that isn’t available to other traders.

Undisclosed Principal Transactions

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The SEC recently announced charges against two Houston-based investment advisory firms and three executives for engineering thousands of principal transactions through their affiliated brokerage firm without informing their clients. In a principal transaction, an investment adviser acting for its own … Continued

Cherry-Picking

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So what is cherry-picking?  The SEC gives a good description in a recent enforcement case (In the Matter of MiddleCove Capital, LLC and Noah L. Meyers): “Myers executed his cherry-picking scheme by unfairly allocating trades that had appreciated in value … Continued